AKG Code of Conduct

This Code of Conduct outlines standards to ensure working conditions at AKG and AKG`s suppliers, sub-contractors and business partners in a sales support capacity, are safe, employees are treated with respect and dignity, manufacturing processes are environmentally responsible, and business is conducted in an ethical manner.

This Code of Conduct applies to all AKG entities located in the United States of America and their employees as well as AKG`s suppliers, sub-contractors and business partners in a sales support capacity, such as agents and trade representatives.

Established in 1919 as an internationally operated family-owned business in its third generation, AKG enjoys a good reputation worldwide.

AKG`s corporate principles are:

Long-term continuance of the family-owned business
Preservation of independence
Continuous improvement of processes and products
Continuous healthy growth
High flexibility
Efficient use of investments
Employer and employees as reliable partners
Success factors for further development of AKG and its employees are embracing change, taking responsibility and promoting teamwork.

In addition, AKG is committed to fundamental ethics and conduct guidelines linked to the key issues of human rights, occupational safety, environmental protection, and fighting corruption which in turn are substantiated by the ten principles of the Global Compact of the United Nations. Compliance with the procedures described in this Code of Conduct will help to promote AKG`s long-term business success.

1. Law abidance:

AKG complies and expects its suppliers, sub-contractors and business partners in a sales support capacity, to comply with all applicable laws including, without limitation, any requirements under federal, state, and local laws.

2. Fighting corruption:

AKG opposes and expects its suppliers, sub-contractors and business partners in a sales support capacity, to oppose any type of corruption including extortion, fraud, or bribery. Therefore AKG cannot approve the act of offering or accepting sums of money suitable for influencing business decisions when initiating or awarding a contract. AKG accepts gifts or entertainment if they are consistent with common business practices, but do not exceed $50.00 in value and cannot reasonably be construed as a bribe or payoff. AKG will not accept any benefit intended for an AKG employee to facilitate business with AKG.

3. Fundamental rights of the employees:

AKG does not and expects its suppliers, sub-contractors and business partners in a sales support capacity, not to tolerate any form of discrimination in hiring and employment practices on the grounds of age, race, color, national origin, religion, sex, disability, or other characteristics protected by applicable law. AKG creates and expects its suppliers, sub-contractors and business partners in a sales support capacity, to create and maintain an environment that treats all employees with dignity and respect and does not use any threats of violence, sexual exploitation or abuse, verbal or psychological harassment or abuse. No harsh or inhumane treatment, coercion, or corporal punishment of any kind is tolerated, nor is there to be a threat of any such treatment.

4. Conflict of interest:

It is of great importance for AKG to not become involved in conflicts of interest while conducting its business. For that reason, AKG only permits itself to be guided by company interests for professional obligations and avoid activities that are contrary to the business interests or the fulfilment of these obligations. AKG employees are required to keep private interests and the interests of AKG strictly apart. AKG employees are required to refrain from any misuse of a position within the company, or using company information or company property for personal purpose or for inappropriate advantages for third parties.

5. Confidentiality:

AKG protects and upholds the property, assets and business opportunities of AKG. Corporate trade secrets not publicly available related to AKG, its suppliers and other business partners, are used strictly confidentially, and never passed on to unauthorized third parties.

6. Health and safety of the employees at work:

AKG is aware that social justice is a basic requirement for sustainable peace and therefore opposes the following forms of work force abuse:

AKG does not accept and expects its suppliers, sub-contractors and business partners in a sales support capacity, not to accept any form of forced or compulsory labor. AKG and its suppliers, sub-contractors and business partners in a sales support capacity, will not require employees to surrender personal certificates and identifications such as government-issued identification, passports, or work permits as a condition of employment. AKG complies and expects its suppliers, sub-contractors and business partners in a sales support capacity, to comply with all laws and regulations governing child labor and apprenticeship programs.

AKG complies and expects its suppliers, sub-contractors and business partners in a sales support capacity, to comply with all applicable requirements governing working hours as established by local law. AKG will not accept and expects its suppliers, sub-contractors and business partners in a sales support capacity, not to accept any form of active or passive discrimination in the employment relationship.

AKG complies and expects its suppliers, sub-contractors and business partners in a sales support capacity, to comply, at a minimum, with all laws and regulations relating to wages including those pertaining to minimum wages, overtime wages, piece rates, and other elements of compensation including legally mandated benefits.

AKG recognizes and expects its suppliers, sub-contractors and business partners in a sales support capacity, to recognize the importance of open communication and direct engagement between employees and management. Additionally AKG respects and expects its suppliers, sub-contractors and business partners in a sales support capacity, to respect the rights of employees to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference, or reprisal.

AKG is fully aware of its responsibility for the health and safety of its employees and therefore considers it an important task to regularly train employees in the area of industrial safety and to take preventive measures in terms of work-related incidents and occupational illnesses. AKG follows and expects its suppliers, sub-contractors and business partners in a sales support capacity, to follow all relevant legislation, regulations, and directives in the country which they operate or at any other location where production or work is undertaken to ensure a safe and healthy workplace. The suppliers, sub-contractors and business partners in a sales support capacity, are expected to ensure, at a minimum, reasonable access to drinking water, sanitary facilities, fire safety, emergency preparedness and response, industrial hygiene, adequate lighting and ventilation, management of occupational injury and illness, and machine safeguarding.

7. Environmental protection:

AKG considers protecting the environment and its natural resources, by means of a sustainable and fair economy that attempts to balance the requirements of our current and future generations, one of the most important goals in maintaining, protecting, and restoring the integrity of the earth`s ecological system.

AKG has therefore made it its very own task to continuously improve environmental protection by using its own available resources and reducing its environmental pollution to ensure that AKG operates as healthily and productively as possible in harmony with nature.

To meet these goals, AKG already applies the ISO 14001 environmental management system at selected plants and is certified accordingly.

AKG expects its suppliers, sub-contractors and business partners in a sales support capacity, to have an environmental policy statement.

8. Supply chain:

AKG will ensure its suppliers, sub-contractors and business partners in a sales support capacity, such as agents and trade representatives, observe the content of this Code of Conduct in an appropriate manner. To do so, AKG will include a reference to the Code of Conduct in all purchasing documents which will become the contractual basis for every purchase order. AKG`s suppliers, sub-contractors and business partners in a sales support capacity, such as agents and trade representatives can access and review the Code of Conduct at any time by visiting AKG`s website at www.akg-america.com.

9. Review/Auditing:

AKG will ensure compliance with the principles and requirements of the Code of Conduct at its own discretion using appropriate internal reviews at regular intervals or with an audit performed by external, independent third parties.

AKG reserves the right to audit suppliers, sub-contractors and business partners in a sales support capacity, - even on site - to ensure compliance with the Code of Conduct. This will be done under consideration of business concerns, as well as the business secrets of the suppliers, sub-contractors and business partners in a sales support capacity, either through AKG, or its representatives, or a third party contracted by AKG who is acceptable to the suppliers, sub-contractors and business partners in a sales support capacity.

10. Appointment of a central point of contact:

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